Civil Recoveries: A New Necessity for Large Wire Fraud Losses

The traditional wisdom has been that fraudulent wires and ACH transfers cannot be recovered, and that notifications to the Federal Bureau of Investigations and sending bank are the only options for recovery. The pursuit of civil recoveries of wire fraud for large losses has become necessary because the FBI no longer will freeze fraudulent wires and bank anti-money laundering processes fail more than they succeed. Recovery efforts targeting transfers of funds by perpetrators and bank activities have produced surprisingly successful results where actions of the FBI and sending banks have failed.